Moxtra, Inc. (“Moxtra”) is committed to protecting your privacy and ensuring you have a positive experience on our website and in using our products and services (collectively “Products”). Moxtra provides a collaboration service that enables users to share and annotate documents and other materials and to communicate via messaging and web meetings.  Moxtra also licenses its collaboration technology to third-party developers to embed in their own applications (“Moxtra-enabled Apps”).  This policy covers the Moxtra website and Products and is applicable worldwide and information collected by Moxtra from Moxtra-enabled Apps. This policy outlines our personal information handling practices for both online and offline data.

This privacy policy describes the types of personal information we collect and process, how we use it, how long we keep it, when it is shared, how you can manage it, and how we secure it.

If you give us personal information, we will treat it according to this policy. This policy may be updated from time to time and our website will indicate when the policy has been updated. You may access the current version at any time by clicking on the “Privacy Policy” link at the footer on our website.  In some agreements with our customers and licensees, we may have provisions related to handling of personal information which may supersede the provisions of this privacy policy.

What kinds of information do we collect?

We collect a variety of “Personal Information” which can include information that can be used to identify an individual, such as name, email address, postal or other physical address and job title.  We collect such information from users of our Products.  In connection with billing customers, we may also collect financial information such as credit or debit card number, bank account numbers, and customers’ billing and payment history. Our Products allows users to post and communicate all types of content, which may include Personal Information regarding individuals.

In some cases, Personal Information from Moxtra-enable Apps is collected and retained by Moxtra.

We collect Personal Information related to persons who we believe might be interested in our Products and media and industry contacts for use in marketing and promotional activity.

We collect information from visitors to our website, including the pages visited, how long individuals viewed each page, the devices used when visiting our website, and information from “cookies” (see below).

We also collect and retain Personal Information relating to our employees as necessary to run our business and Personal Information submitted by job applicants.

How do we use this information?

We use this information:

  • to communicate with our customers regarding their use of our Products,
  • to provide technical support to our customers,
  • to bill our customers and communicate with them regarding their accounts,
  • to provide information and engage in marketing activities regarding our Products,
  • to provide profiles of users of our Products
  • to enable the use of our Products, and
  • to improve our Products.

Information related to employees is used in connection with their employment at Moxtra.  Information related to job applicants is used in recruiting and hiring processes.

How long do we keep this information?

Information related to an individual associated with one of our customers is retained while the customer relationship is in place (and to complete any post-termination transactions or wind-down of activities) or until we are advised that the individual is no longer associated with that customer.

Information related to individuals who are contacted for marketing and promotional purposes is retained until they indicate they no longer wish to be contacted (e.g., unsubscribing from email solicitations).

Information related to individuals will generally be deleted when the purpose for which the information was being used no longer exists.

When do we share personal information?

We do not sell or rent your personal information to third parties for purposes unconnected to our uses of the information described above.  However, we may provide personal information to other parties to help us accomplish the uses described above.  Such sharing of information includes:

  • parties which we contract with to help us provide the Products, including subcontractors, agents and third party service providers (such as data centers),
  • parties who assist us in our marketing and promotional programs, and
  • parties which assist us with payment processing services.

We provide the third parties with the minimum amount of personal information necessary to fulfill the terms of the predetermined service or transaction, and none of these third parties are permitted to use your personal information except for the purpose of providing a specific service on behalf of Moxtra. Moxtra is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequent transfers to a third party acting as an agent on its behalf. Moxtra complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

We may also provide information to third parties in connection with legal matters, which includes:

  • providing information where we are legally obligated to do so (such as subpoenas or court orders), and
  • in connection with the investigation, prevention or assisting law enforcement with respect to suspected or known illegal activities, fraud, threats, violations of our terms of service, or as otherwise required by law.

We will ask for your consent before we use or share your information for any purpose other than the reason you provided it or as otherwise provided by this policy. In order to let us know your preferences, we will require an action on your part, such as checking the appropriate option, to indicate your consent.

How can I manage my personal information retained by Moxtra?

If you believe Moxtra is in possession of your Personal Information that you want modified or deleted, you may send an email request to privacy@moxtra.com. We may need to retain some Personal Information for the period of time necessary for legal proceedings, legal requirements or for settling your account.

Unsubscribing and Opting Out: Each promotional email from Moxtra or from third parties to whom Moxtra has given your email address with your consent includes instructions on how you can unsubscribe from that category of mailing or from receiving email from that third party. You may also unsubscribe from Moxtra’s promotional emails by sending an email, including your name and email address to unsubscribe@moxtra.com, or a letter to:
Moxtra, Inc.
Attn: Privacy Officer
1601 S. De Anza Blvd, Suite 217
Cupertino CA 95014
If you have additional questions regarding your disclosure choices and Moxtra’s policies regarding receipt of promotional email, you may contact Moxtra by sending an email with your name and email address to privacy@moxtra.com.

Moxtra may obtain some Personal Information regarding you from Facebook. In order to keep your Personal Information accurate and up to date or to delete any Personal Information, you will need to manage that through your Facebook account. We do not have the ability to modify or delete your Facebook Personal Information.

How do we secure your information?

Moxtra is committed to protecting the Personal Information you share with us. We utilize a combination of industry-standard security technologies, procedures, and organizational measures to help protect your Personal Information from unauthorized access, use or disclosure.

When we transfer credit card information over the Internet, we protect it using Secure Sockets Layer (SSL) encryption technology. While we strive to protect your Personal Information, we cannot ensure the security of the information you transmit. We recommend you to take every precaution in protecting your Personal Information when you are on the Internet. For example, change your passwords often, use a combination of letters and numbers when creating passwords, and make sure you use a secure browser.

EU-U.S.& SWISS-U.S.PRIVACY SHIELD:
Moxtra complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Moxtra has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms of this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

Moxtra’s accountability for personal data that it receives under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield principles. In particular, Moxtra remains responsible and liable under the Privacy Shield principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the principles unless Moxtra proves that it is not responsible for the event giving rise to the damage.

If you have inquiries and concerns that you would like to discuss with us relating to personal data received under the EU-US Privacy Shield privacy shield framework or Swiss-US Privacy Shield framework and, please contact us at privacy@moxtra.com. Moxtra will respond to your inquiry within 45 days. If, after contacting us, we fail to adequately address your concern, please contact our U.S.-based third-party dispute resolution provider, American Arbitration Association, at http://go.adr.org/privacyshield.html. The services of American Arbitration Association are provided at no cost to you. Moxtra is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

Use of Cookies and Web Beacons

Non-personal/anonymous information collection: In some instances, Moxtra may collect non-personal (aggregate or demographic) data through cookies, web logs, and web beacons. This information is used to better understand and improve the usability, performance, and effectiveness of the website. Please read the “Cookies” section below for more information. In addition, by using some of our Products, anonymous network information may be transmitted back to us such as Product usage information. This information is transmitted back to us so we can determine how users are interacting with our Products, to assist us with improving our Products, and to correct any problems that may occur.

Cookies: Like many websites, Moxtra uses technologies, such as cookies and web beacons, which allow us to make your visit to our website easier, more efficient and more valuable by providing you with a customized experience and recognizing you when you return.

A cookie cannot read personal data off your hard disk or read cookie files created by other sites; indeed, the only Personal Information a cookie can contain is information you supply yourself. Accepting the cookies used on our website may give us access to information about your browsing behavior, which we may use to personalize your experience and track user traffic patterns, and to merge this info when you register. We do this in order to determine the usefulness of our website information to our users and to see how effective our navigational structure is in helping users reach that information. You may browse most of Moxtra’s website without accepting cookies from Moxtra; however, some website functionality may be lost by disabling cookies on your computer. Other Moxtra web pages, particularly those which require a login and password, require cookies and cannot be used when you have disabled cookies in your browser.

In addition, Moxtra uses web beacons in conjunction with cookies to understand user behavior. Web beacons are simply a convenient way of gathering basic statistics and managing cookies and do not give away any extra information from your computer. Turning off your browser’s cookies will prevent web beacons from tracking your specific activity. If you prefer not to receive cookies while browsing our website or via HTML-formatted emails, you can set your browser to warn you before it accepts cookies or refuses the cookie when your browser alerts you to its presence. You can also refuse all cookies by turning them off in your browser. You may browse most of the Moxtra website without accepting cookies; however, some website functionality may be lost by disabling cookies on your computer. Other Moxtra web pages, particularly those which require a login and password, require cookies and cannot be used when you have disabled cookies in your browser. For additional information about cookies and other tracking technologies, including instructions for blocking their use, see http://privacy.getnetwise.org/browsing/tools.

Third Party Websites and Services

While navigating Moxtra’s web site or Products you may be directed to content or functionality that is hosted by a third-party supplier. When information is collected on behalf of Moxtra exclusively, Moxtra’s privacy policy will be referenced and will govern how your information is used. For other, non-Moxtra sites or services, the site/service owner’s privacy policy will be referenced. You should review such supplier’s privacy and security policies prior to use.

Our websites and services may provide links to other third-party websites and services which are outside our control and not covered by this policy. We encourage you to review the privacy policies posted on these (and all) sites you visit or services you use.

Posting Content using Moxtra Products

If you provide or upload content using a Moxtra Product, you should be aware that the information you provide there may be made broadly available to others, potentially inside or outside Moxtra, who have access to that Moxtra binder or another content repository. Any content provided by a user is solely the responsibility of that user and should not be considered as reflecting the opinion of Moxtra.

Children’s privacy

Moxtra does not knowingly collect Personal Information from children under the age of 13. If we learn that we have collected Personal Information on a child under the age of 13, we will delete that data from our systems. Moxtra encourages parents and guardians to go online with their children. Here are a few tips to help make a child’s online experience safer: Teach children never to give Personal Information (such as name, address, phone number, school, etc.) unless supervised by a parent or responsible adult. Know the sites your children are visiting and which sites are appropriate.
Look for website privacy policies. Know how your child’s information is treated. Please visit the FTC’s website for more tips on protecting children’s privacy online.

Consent to Transfer, Processing and Storage of Personal Information

We may transfer your Personal Information to the United States, to any Moxtra affiliate worldwide, or to third parties acting on our behalf for the purposes of processing or storage, and by providing any Personal Information you fully understand and unambiguously consent to such transfer, processing and storage of such information.

Questions or comments? Should you have any privacy-related questions or comments related to this privacy policy, please send an email to privacy@moxtra.com.

Policy updates: Moxtra may amend this privacy statement from time to time, and at any time. We will post a notice whenever this privacy statement is materially changed. Your continued use of the Moxtra website or Products after any change will signify and confirm your assent to those changes.

 

Provisions Specific to EU Citizens

Rights of EU Citizens Under the GDPR

If you are a citizen of the European Union you have certain rights relating to how others handle your personal information.  These rights are:

  1. The right to be informed how your personal information is being used.
  2. The right of access your personal information and how it is processed.
  3. The right to rectify personal information which is inaccurate or incomplete.
  4. The right to erasure – also known as ‘the right to be forgotten’, this refers to an individual’s right to have their personal data deleted or removed.
  5. The right to restrict processing, that is, the right to block or suppress processing of your personal data.
  6. The right to data portability – this allows individuals to retain and reuse their personal data for their own purpose.
  7. The right to object, in certain circumstances, to use your personal data in a manner different from the purpose for which it was provided.
  8. Right to prevent automated decision making or profiling based on your data without human intervention.

The identity of Data Controller

When an individual is providing personal information in connection with the use of our Products in their capacity as an authorized user of a company which does business with Moxtra, the data controller is generally going to be that company.  This will also be true where personal information is being collected by Moxtra in connection with the use of a Moxtra-enabled App.

If an individual is providing personal information directly to Moxtra, for example, as a Moxtra employee, a visitor to Moxtra’s website, or a party consenting to receive information regarding Moxtra and its Products, then Moxtra is generally going to be the data controller.  In circumstances where Moxtra is the data controller, you can contact us at the email and physical addresses provided above in the section named “How can I manage my personal information retained by Moxtra?”

 

Data Processing Addendum